Target Market Statements FAQs
Here you'll find the most frequently asked questions about our Target Market Statements.
Our Commercial Lines and intermediated Personal Lines TMS (including fair value assessment outcome and conclusion) for our open market products are available here.
We are not publishing the TMS of any delegated or scheme arrangement with exclusive product wordings or co-manufacturer arrangements on our website. Our delegated partners and brokers have been emailed their TMS directly. If you cannot locate the email and need it resent, please contact our dedicated mailbox: email@example.com.
As a product manufacturer, we determine the definition of our products. We have applied the FCA guidance whereby products can be grouped if the cover and customer outcomes are similar, and the intended target market is consistent. However, we appreciate that our product naming conventions may not fully align with yours and may cause confusion.
To help you locate the TMS relevant to you, we have intentionally presented our TMS documents by portfolio, for example, Commercial Packages. Please also be aware that we have not created individual TMS for each section of cover within our policies, or where that cover is part of another product, such as Terrorism.
If you are unable to find the TMS relevant to your firm, please contact us via our dedicated mailbox firstname.lastname@example.org or your usual RSA contact.
If your delegated arrangement is in run-off, so you will not be distributing new business or renewals after 1 October 2022, we have not published a TMS for your product. However, if you have any questions, please contact our dedicated mailbox: email@example.com
If you have a specific query regarding your delegated arrangement or scheme, due to the individual complexities of your arrangement with us, please direct your question to our dedicated mailbox: firstname.lastname@example.org.
Yes, we did. We have worked hard to ensure the design of our Product Governance Framework and associated processes are customer centric. The questions that we use to support our product reviews address both customer outcomes and fair value considerations.
We use questions that balance quantitative (i.e., metrics) and qualitative information (e.g., processes and controls) to inform our view of product value. The exact metrics used vary by product review, but we have generally considered the following:
- Loss ratio
- Combined operating ratio
- Claims acceptance rate
- Claims complaints (as a % of claims)
- Claims frequency
- Claims walkaways
- Average claims pay-out
- Operations pre and post-sales service
- Claims service
- Complaints service
- Fees and charges (and other remuneration).
Other metrics are considered (including metrics to provide context), where relevant, and we have also used other internal and external insight.
Each TMS includes our fair value assessment outcome and conclusion. Please refer to the section ‘How is the value of this Product assessed?’ for a high-level summary of how we established whether the product is compatible with the objectives, interests and characteristics of the target market and if product value has been impacted by the distribution strategy.
Please refer to the section ‘How is the value of this product assessed?’ within each TMS. If there are no issues, we have concluded that the product provides fair value to customers. If any issues were identified, this is clearly stated in the fair value assessment outcome and conclusion.
Please refer to the section ‘How is the value of this Product assessed?’ within the TMS for details of any material actions arising from our product reviews.
Rest assured, if action is required by your firm, we will contact you directly to make you aware.
Unless we have a co-manufacturing relationship with your firm, we will not share more detailed data and/or information in respect of our product review. If we have a co-manufacturing relationship with your firm, then we will share relevant documents with you directly. These documents will not be published openly on this website.
We have deliberately designed our TMS document to meet relevant regulatory rules and help our distributors to meet their obligations.
We use questions that balance quantitative (i.e., metrics) and qualitative information (e.g., processes and controls) to inform our view of the impact of distribution on product value. Our questions include consideration of price-setting, remuneration (including commissions, fees and charges and other payments), conflicts of interest, distribution methods, types of entity in the distribution chain, as well as other relevant insight.
The Financial Conduct Authority (FCA) has set out in a letter to distributors dated 29 July 2022 the circumstances that must be met for the forbearance (a 3-month period until 1 January 2023) to apply. They are as follows:
- The distributor has identified the impact the distribution arrangements have on the value of the product by 30 September 2022 and has completed any identified remedial action as a result of the assessment.
The distributor has complied with any requests from the manufacturer for information specific in PROD 4.3.10BR.
The distributor is able to demonstrate that they received the manufacturer’s value assessment too late for them to be reasonably expected to meet their obligations by 30 September 2022.
We review all our in-scope General Insurance products at least annually. Our next cycle of reviews is due to be performed during the first half of 2023.
We will refresh our TMS once our next cycle of product reviews has been completed. We will notify relevant distributors and partners of material changes to the documents. You can expect all documents to be refreshed by Q3 2023.
Our up-to-date documents are held on our website and are periodically reviewed. Please be aware that the documents are subject to change, meaning you should refer to this site for the latest version.